Travel Rule Policy | Vision Makers Docs

This Policy sets out how Vision Makers Technologies Inc. approaches FATF Recommendation 16, the "Travel Rule", for virtual asset transfers.

Applicability must be confirmed The Travel Rule applies to Virtual Asset Service Providers. Vision Makers operates a non-custodial interface: users transact from wallets they control, and the platform does not hold, transmit or exchange assets on their behalf. Whether any Vision Makers activity falls within VASP scope in a given jurisdiction must be confirmed by counsel. This Policy states the position we apply where it does, and the controls we operate regardless.

1 · The requirement

Where a VASP transfers virtual assets on behalf of a customer, it must obtain, hold and transmit required originator and beneficiary information to the counterparty institution, and make it available to authorities on request.

Typically required: originator name, account/wallet identifier, and address or national identifier or date and place of birth; beneficiary name and account/wallet identifier.

2 · Our position

Non-custodial transfers. When you swap or transfer from your own wallet, you are the originator and you control the transaction. Vision Makers is not a transferring institution for that transaction and does not transmit Travel Rule data on your behalf.

Where we are in scope. For any feature where Vision Makers does act as an obliged entity, including any future custodial, fiat on-ramp or brokered arrangement, we will collect and transmit required information before the transfer executes, and will not proceed where required information is missing.

3 · Thresholds

Where applicable, the de-minimis threshold is USD/EUR 1,000 (or the local equivalent), below which reduced information may be transmitted, subject to jurisdictional variation. Several jurisdictions apply a zero threshold; the stricter standard applies where our user is subject to it.

4 · Unhosted and self-hosted wallets

Transfers to and from self-hosted wallets receive risk-based treatment: blockchain analytics screening of the counterparty address, and, where risk indicators or legal requirements demand it, wallet ownership verification before proceeding.

5 · Counterparty due diligence

Before exchanging Travel Rule data with another institution we assess that it is a legitimate, appropriately regulated entity able to protect the data and that the exchange is lawful. Data is transmitted over secure, interoperable channels.

6 · Sunrise issue

Where a counterparty is in a jurisdiction that has not implemented the Travel Rule, we apply a risk-based decision on whether to proceed, documenting the rationale.

7 · Data protection

Travel Rule data is personal data. It is collected, transmitted and retained only as required, protected in transit and at rest, retained for five years, and handled under the Privacy Policy.

8 · Records and refusal

Records of transmitted and received information are retained for five years. We may delay or refuse a transfer where required information is missing, where screening raises an unresolved flag, or where proceeding would breach sanctions.

Contact

admin@visionmakers.io